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Judicial review allowed where the Federal Court found the CRA’s taxpayer-relief decision under s. 220(3.1) of the Income Tax Act was unreasonable.
Federal Court dismissed an application for judicial review of CRA taxpayer-relief denials for 2021 and 2022, finding the decision reasonable and procedurally fair.
The Federal Court dismissed judicial review of the CRA’s refusal to grant full taxpayer relief from interest on McMillan’s 2005 tax debt, finding the decision reasonable and fair.
The Federal Court granted judicial review of a taxpayer-relief refusal, finding the CRA delegate failed to address key errors and hardship under s. 220(3.1).
Federal Court dismissed a judicial review of the Minister’s refusal to waive interest under s. 220(3.1) of the Income Tax Act, finding the decision reasonable.
The Federal Court dismissed a judicial review of a partial taxpayer-relief decision, finding the CRA’s refusal of further interest relief was reasonable.
Judicial review of the Minister’s refusal to waive interest under s. 220(3.1) of the Income Tax Act was dismissed because the decision was reasonable.
The Minister's delegate reasonably considered the appellants' submissions and the relevant CRA processing delays (including the 1985–1990 period), concluded that delays had been addressed in prior reviews and that taxpayers had options (via intercept letters) to avoid interest accrual; the delegate's transparent, intelligible analysis justified denying further interest relief, and the Federal Court properly upheld that reasonable decision, so the appeal is dismissed.
Source excerpt
The Federal Court held the Minister unreasonably failed to address CRA delay in processing a late objection, and sent the matter back for redetermination limited to interest from that delay.
Judicial review of a CRA refusal to waive $3,941.66 in arrears interest was dismissed. The Court found the delegate’s decision reasonable despite alleged delay, error, and fraud-related hardship.
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